On 13 May 2025, U.S. President Donald Trump announced that his administration will start "restoring the normal relationship" with Syria's new government and "ordering the cessation of sanctions against Syria." While, at the time of publication, there have been no material changes to U.S. sanctions obligations involving Syria, K2 Integrity is publishing this note to provide context and insight into potential next steps.
Background on U.S. Sanctions
Syria has been designated as a state sponsor of terrorism by the United States since 29 December 1979. Starting in May 2004, the United States has issued eight executive orders targeting Syria with sanctions for various reasons. In August 2011, in response to Syria's escalating civil war, President Barack Obama issued Executive Order 13582, which imposed a comprehensive embargo on Syria and blocked the assets of the Government of Syria.
Currently, the U.S. economic prohibitions involving Syria are as follows:
- Blocking property and interests in property (i.e., asset
freeze)—
- Government of Syria; and
- Hundreds of individuals and entities designated due to their ties to the Assad regime, involvement in human rights violations, corruption, terrorism, sanctions evasion, or proliferation of chemical weapons;
- Comprehensive ban on the export of goods and services, with limited exceptions;
- Ban on new investment by U.S. persons;
- Ban on imports of Syrian petroleum or petroleum products into the United States and any transaction or dealing in Syrian petroleum or petroleum products by a U.S. person, wherever located; and
- Comprehensive arms embargo.
In addition to the comprehensive sanctions that target Syria broadly, several individuals and entities have been individually targeted with sanctions due to reasons other than having ties with Assad's regime in Syria, including terrorism, proliferation of weapons of mass destruction, sanctions evasion, or under other sanctions programs such as Iran and Russia, among other national security and foreign policy reasons. Of note, Hayat Tahrir al Sham (HTS) and its leadership, which are currently governing Syria, are subject to U.S. sanctions as terrorists. Absent a license or waiver, U.S. persons are prohibited from engaging in any transaction or dealing involving their property or interests in property—which severely complicates U.S. engagement with both the Syrian government, and in Syria more generally.
- In May 2018, the State Department added HTS as an alias of the Nusrah Front, which is designated as a Foreign Terrorist Organization (FTO) and a Specially Designated Global Terrorist (SDGT).
- The State Department designated HTS leader Al Sharaa as an SDGT pursuant to Executive Order 13224 in 2013, following the United Nations Security Council's (UNSC) designation of him.
- HTS is also designated by the UNSC as an alias for the Nusrah Front, which was listed on 14 May 2014 pursuant to paragraphs 2 and 3 of resolution 2083 (2012) as being associated with Al-Qaida for "participating in the financing, planning, facilitating, preparing, or perpetrating of acts or activities by, in conjunction with, under the name of, on behalf of, or in support of" and "recruiting for; or otherwise supporting acts or activities of" Al-Qaida and Al-Qaida in Iraq.
In addition to the executive branch actions, Congress has passed the following legislation "requiring" the president to impose certain sanctions on Syrian state and non-state actors, although these laws provide for Presidential discretion—
- Syria Accountability and Lebanese Sovereignty Restoration Act of 2003;
- Iran Threat Reduction and Syria Human Rights Act of 2012; and
- Caesar Syria Civilian Protection Act of 2019.
International Action
Outside of the United States, both the EU and the UK have already started relaxing some of their restrictions involving Syria, which were not as broad as those implemented by the United States.
On 24 February 2025, the EU Council removed the Agricultural Cooperative Bank, Industrial Bank, Popular Credit Bank, Saving Bank, and Syrian Arab Airlines from the list of its sanctions targets; suspended some of the restrictions related to Syria's energy and transport sectors; and introduced exemptions to allow certain banking relationships between European and Syrian banks. In March and April 2025, the United Kingdom also removed several names from the list of its sanctions targets, including the Syrian Ministry of Interior, Ministry of Defense, the General Intelligence Directorate, as well as several Syrian TV stations.
How Sanctions Programs Are Lifted
The president can rescind state sponsor of terrorism designations under one of two mechanisms:
- If he submits a report to Congress before the proposed rescission would take effect certifying that (i) there has been a fundamental change in the leadership and policies of the government of the country concerned; (ii) the government concerned is not supporting acts of international terrorism; and (iii) the government concerned has provided assurances that it will not support acts of international terrorism in the future; or
- If he submits a report to Congress at least 45 days before the proposed recession would take effect, certifying that (i) the government concerned has not provided any support for acts of international terrorism during the preceding six-month period; and (ii) the government concerned has provided assurances that it will not support acts of international terrorism in the future.1
While the president can choose either mechanism, the approach will likely depend on congressional dynamics, the international demand for movement, and practical limitations that arise from the continued state sponsor of terrorism designation.
Absent legislative restrictions, the U.S. government can modify existing sanctions, substantially or in part, through the issuance of an OFAC General License (GL), including the ban on the export of services, the new investment ban, and the prohibition on transactions or dealings involving the petroleum sector. Such general licenses authorize activities that were otherwise prohibited for U.S. persons, but they do not remove the sanctions completely. The Commerce Department's Bureau of Industry and Security can similarly modify the export restrictions through amendments to the Export Administration Regulations (EAR). Lastly, the President can more broadly rescind sanctions through the issuance of a new executive order that terminates national emergencies previously declared under the authority of the International Emergency Economic Powers Act (IEEPA). While the U.S. government can scale back or eliminate sanctions and asset freezes, it may consider wind-down periods or other actions to preserve ongoing diplomatic or other equities, such as claims by U.S. persons or financial institutions against frozen assets.
Note: At the time of publication, these actions have not yet been taken and there is no material change to U.S. sanctions obligations related to Syria.
Some Outstanding Questions
What could lifting sanctions against Syria look like?
The United States—together with its partners—could sequence sanctions relief in a way that facilitates humanitarian relief, and promotes reconstruction and investment in Syria, while balancing diplomatic considerations and domestic considerations. For example, the U.S. government could take a measured approach that scales back—or suspends—sanctions through GLs and other interim measures on an incremental basis, or it could take more rapid steps to terminate particular sanctions. Some considerations include the need to provide certainty for U.S. businesses seeking to engage in trade or investment in Syria; the overall U.S. relationship in the region, and in particular, with Israel, Saudi Arabia, and Turkey; HTS ties to Al-Qaida and other terrorists; and humanitarian needs and other U.S. interests.
For example, the president could immediately rescind the state sponsor designation with advance notification to Congress based on a change in regime and appropriate commitments from HTS to refrain from terrorism. The State and Treasury Departments could use that basis to rescind the HTS designation as an SDGT—or issue an appropriately crafted General License. The United States could also generally license most investment restrictions and transactions involving the petroleum sector—in order to promote revenue growth in Syria as well as U.S. investment in the country. The Treasury and Commerce Departments could work together to appropriately license the export of goods and services in a manner that protects U.S. national security interests but facilitates the reconstruction of Syria. The United States would need to consider over time the disposition of blocked assets in the United States (e.g., to allow the disposition of claims against those assets), but could license new activities and transactions involving the Syrian government. Lastly, the changes in sanctions policy could be coupled with coordination with U.S. development agencies and multilateral development banks to facilitate and expedite positive change in the region.
Can the president lift sanctions without congressional or other actions?
Possibly. To the extent that the U.S. government has imposed sanctions pursuant to Syria-specific legislation, the relevant laws each have a waiver or termination section, which would allow the president to suspend or terminate the sanctions required by the act in question.
How to deal with any remaining sanctions?
OFAC has designated several individuals and entities as Specially Designated Nationals (SDNs) in Syria under other sanctions programs including Iran, Russia, Global Magnitsky—which targets corruption and human rights abuses—and terrorism. OFAC could issue GLs that would authorize some or all transactions involving property and interests in property in those SDNs, consistent with U.S. interests, or refrain from any action at all. It is unlikely that there will be a broad suspension or removal at this stage of sanctions imposed under other programs, except for those that target HTS and the new leader of Syria.
Prior to removal from the SDN List of HTS—the current governing party in Syria, and its leader—the United States (or another country) would likely request that the United Nations Sanctions Committee established pursuant to UNSC resolutions 1267 (1999), 1989 (2011), and 2253 (2015) remove HTS from its list of sanctioned entities.
K2 Integrity will continue to monitor material developments regarding sanctions targeting Syria and will provide updates as available.
Footnote
1 See 22 U.S.C. 2371(c), 50 U.S.C. 2405(j)(4), or 22 USC 2371(c).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
